China Regulatory Research · Industrial Robotics

Industrial Robotics: documentation and language requirements in China

For industrial robots, Article 27 of the Product Quality Law addresses Chinese product identification and, for relevant hazards, warning marks or Chinese warning instructions. This provision alone does not establish that every part of an operating manual or HMI must be Chinese. Check applicable product and standard requirements separately.

Authority SAMRSource record 2026-09-04Editorial update 2026-10-11
Compiled from public sources

Compiled from public official sources. The source retrieval dates below apply to the cited findings; this editorial review does not revalidate every provision or current standard edition. A language requirement marked to verify has not been established from the cited text. Confirm current product-specific requirements before filing or making an external commitment.

Language requirements by document type

Each row states what was established, the provision it rests on, and when it was retrieved. Rows marked to verify are ones this research could not settle against an official provision — they are shown rather than omitted.

DocumentChinese requiredDetailBasisSource
Warning instructions on the machine and in the manualRequired Article 27, item (5) requires products that may damage themselves or endanger persons or property if used improperly to carry warning marks or Chinese warning instructions. Industrial robots sit squarely inside that description, which makes the Chinese warning text a compliance artefact rather than a convenience for the operator. Product Quality Law of the People’s Republic of China (as amended 29 December 2018), Article 27, item (5)www.cnipa.gov.cn2026-10-11verifiable
Product identification on the machine or packagingRequired Article 27, items (2) and (3) require the product name and the manufacturer name and address to be marked in Chinese, and require specifications, grade and principal constituent names and contents to be marked in Chinese where the product characteristics and conditions of use call for it. Where the buyer needs to know before purchase, the information must be on the outer packaging or supplied in advance. Product Quality Law (as amended 2018), Article 27, items (2) and (3)www.cnipa.gov.cn2026-10-11verifiable
Safety terminology in operating documentationTo verify The official metadata record lists GB 11291.2-2013 for industrial robot systems and integration as in force, implemented 1 November 2014. Its full normative text was not reviewed, so a specific language or terminology clause is not established here. Confirm the applicable clauses for the product. The standard text itself was not read; its number, title, status and implementation date were verified from the national standards platform.GB 11291.2-2013, Robots and robotic devices — Safety requirements for industrial robots — Part 2: Robot systems and integrationopenstd.samr.gov.cn2026-10-11verifiable
Interface and on-screen textTo verify No provision was located that specifically mandates Chinese for robot interface strings. The recurring problem here is not a language mandate but a mismatch: the manual describes a control by one name and the screen shows another, so an operator following the manual cannot find the control. Interface strings are also where identifiers matched in code get translated by mistake. Recorded as a negative finding: absence of a located provision is not proof that none exists.No specific provision locatedwww.samr.gov.cn2026-09-04portal only

About the source markers

verifiable
The link opens the provision itself — you can check that row by clicking it.
portal only
The link opens the authority's portal. It confirms the body and the scheme, but the specific reference or status on that row cannot be verified from that page alone.

Terminology consistency across submissions

Safety terminology should be aligned across the applicable standard edition, manual, markings and training material. The cited GB 11291.2 record is a starting reference; this research has not read its full normative clauses and does not establish a particular mandated wording.

  • Product Quality Law (as amended 2018), Article 27, item (5) — warning marks or Chinese warning instructions are required for products that may endanger persons or property if used improperly.
  • GB 11291.2-2013 — cited record for industrial robot systems and integration; full normative text not reviewed.
The check that matters is not whether the Chinese reads well but whether the same safety concept carries the same term in the manual, on the machine, on the screen and in the training material. A manual that is internally consistent but diverges from the machine markings still leaves the operator with two vocabularies.

openstd.samr.gov.cn · retrieved 2026-09-04

Where companies get this wrong

01

An English manual is acceptable for professional operators

Article 27, item (5) requires warning marks or Chinese warning instructions for products that may endanger persons or property if used improperly. The provision is written around the hazard, not around the sophistication of the buyer.

www.cnipa.gov.cn
02

Safety terms can be improved if the improvement is clearer

Check defined terms in the applicable standard before editing safety wording. The full normative text was not reviewed in this research, so a specific terminology obligation cannot be inferred from its title alone.

openstd.samr.gov.cn
03

Interface text and the manual can be translated separately

They can be, and that is usually how the mismatch arises. Nothing in the requirements forbids it; the cost lands on the operator who reads a control name in the manual that does not appear on the screen.

www.samr.gov.cn

What documentation problems have led to

No public case naming a document or language problem as the stated cause was found for this sector. What follows is the regulatory position, recorded without predicting outcomes.

Product marking

Chinese product name, manufacturer name and address are required on the product or its packaging, and warning marks or Chinese warning instructions are required where improper use may endanger persons or property. No public case was located tying an enforcement action to robot documentation language.

www.cnipa.gov.cn
Safety standard

The cited record identifies GB 11291.2-2013 for robot systems and integration. Current applicability, full normative clauses and an enforcement consequence for terminology divergence are not established by this research.

openstd.samr.gov.cn

Common questions

Does the operating manual have to be in Chinese?

The provision we can point to directly is Article 27, item (5) of the Product Quality Law, which requires warning marks or Chinese warning instructions where improper use may endanger persons or property. Whether every part of a manual falls inside that wording is a question we would not answer with more confidence than the text supports.

Retrieved 2026-09-04

What has to be marked in Chinese on the machine itself?

Product name and manufacturer name and address, under item (2). Specifications, grade and principal constituents follow under item (3) where the product characteristics and conditions of use require them.

Retrieved 2026-09-04

Which standard governs safety terminology for robot systems?

The earlier research cites GB 11291.2-2013 for robot systems and integration. Confirm the applicable edition and relevant language or terminology clauses in the full text; this review does not establish them from metadata alone.

Retrieved 2026-09-04

Is there a Chinese-language requirement for the HMI?

We did not locate one, and we record that as a negative finding rather than as a conclusion that none exists. The failure we see in practice is mismatch between screen and manual rather than absence of Chinese.

Retrieved 2026-09-04

Our previous manual was approved. Can we reuse the terminology?

Check what standard it was written against before reusing it. Terminology inherited from a superseded standard reads correctly and cites a reference that no longer governs, which is the harder failure to notice.

Retrieved 2026-09-04

Can you certify our documentation meets Chinese safety requirements?

No. We can set out what the cited provisions and standards require, and where your material does not correspond to them, with a source for each point. Certification and legal determinations belong to the competent authority and to qualified professionals in China.

Retrieved 2026-09-04

What this research did not settle

The following could not be established against an official source in this round, and so was not written into the findings above. It is listed so you can see where the research stops.

  • The text of GB 11291.2-2013 was not read; only its number, title, status and implementation date were verified.
  • GB 11291.1 was not separately verified in this pass.
  • Whether a full operating manual, as distinct from warning instructions, carries an explicit Chinese-language mandate was not established.
  • No provision specific to robot interface or HMI language was located; recorded as a negative finding.
  • CCC certification scope for robots and robot systems was not confirmed at document level.

Sources

  • National standards full-text disclosure (openstd.samr.gov.cn)
  • China National Intellectual Property Administration, laws section (cnipa.gov.cn)
  • State Administration for Market Regulation (samr.gov.cn)

Retrieved 2026-09-04

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About this page

This page presents regulatory research intended to help companies understand documentation requirements in a target market. It does not constitute legal advice and is not a substitute for qualified legal counsel.

All regulation numbers, effective dates, and status indicators on this page carry a source and a retrieval date. Regulations may change after that date. For determinations of legal effect, the official-language text and the current rules of the competent authority govern.

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